Spanish pharma wins DOJ declination
Friday, December 7, 2012 at 7:51AM
The FCPA Blog in Bayer, Belarus, Brazil, Bulgaria, China, Declinations, Georgia, Grifols, Iran, Libya, Russia, Talecris

In an SEC filing this week, Spanish pharmaceutical firm Grifols SA said the DOJ issued an 'official declination to all inquiries related to the possible violation of the Foreign Corrupt Practices Act (FCPA) that were underway since July 2009.'

It said the investigation related to Talecris, acquired by Grifols in 2011.

'These investigations started prior to the acquisition of Talecris by Grifols,' the company said, 'and correspond to actions carried out when Talecris was part of the Bayer Group.'

Grifols said it has been cooperating with the DOJ by reporting all internal findings about potential FCPA violations.

As reported this week by the Wall Street Journal, an internal investigation at Talecris examined sales in Belarus, Russia, Iran, Brazil, Bulgaria, China, Georgia, Libya, Poland, Turkey, and Ukraine. Talecris had notified the DOJ in 2009 of the investigation and 'suspended operations in several countries while adding safeguards against foreign bribery, in some cases terminating consultants and distributors,' the Wall Street Journal said.

Grifols said in issuing the declination, the DOJ mentioned 'the significant cooperation of Grifols . . . to secure valuable information and making responsible decisions that [led] to the early disclosure of information to the DOJ.'

The company also said it took remedial action and strengthened its compliance program.

Grifols SA's full FCPA disclosure in its Form 6-K (Report of Foreign Issuer) is here.

Article originally appeared on The FCPA Blog (https://www.fcpablog.com/).
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